ashornehill Creating growth through people Ashorne Hill Management College (A company Ilmited by guarantee) Report and Financial Statements For the year ended 31 March 2021 Company number 00889791 Charlty number 528784 ashornehill creating9￿w[h through p￿)ple Ashorne Hlll Management College (A company Ilmlted by guarant•o) Roport and Flnanclal Statements For the year onded 31 March 2021 Contents Pa Trustees, Annual Report Con801idated St8tement of Financkql Actlvllies 12 Consolidated & Chadty Balance Sheets 13 Consolldated Stat8m8nt of Cashflows 14 Not88 foming part of the financial stslements 15 ashornehill Trustees, Annual Report for the Year Ended 31 March 2021 The Trustees present their rekKVt and audti8d financial statements for the year ended 31 March 2021. R•foronce and Admlnl•tratlv• Inforniatlon Charity Name: Ashome Hill Management College ('AHMC', llhe College.) Charity reglstration number.. 528784 Company regIStrat￿n number. 00889791 Registered Office and Operational address Ashome Hlll Leamington Spa Warwlckshirn CV33 9QW Structur• and Gov•mance The College Is registered as a company limited by guarantee and is governed by lis memor8ndum and articlés of a88ocialion. 11 is registered as a charity with the Charity Commisslon. As defined ty the College's memorandum & articles of assocl8tion, 1he members of the College are the Truslees of AHMC and such other p8rsons or organis8tions as appointed by the Trustees. In the event of being wound up, every member of the Colbge undertakes to contribute £1,000 for the payment of the debts arKJ liabilities of the College. The following persons acted as Trustees and Mémbers durlng the financial year: Mr l Hamett (Chalr) Mr D Williams (Chair) MrJ Hall Mr C Elliot Mr R Seacomb8 Ms A Chick Mrs C Bart)er Mr AS IsherwocMI Mrs M Jennings Mr J Carson Mr EJ West Jaguar Land Rover {resKJn8d 6 October 2020) Jaguar Land Rover {apFointed 6th Odober 2020) Jaguar Land Rover Jaguar Land Rover (resigned 17th May 2021) Jaguar Land Rover (resigned 31S1 Oecember 20201 Jaguar Land Rover Jaguar Land Rover Institute of Student Employers Venues of EX￿llenCe (appointed 9th March 2021) AHMC (￿signed 9° Juty 2021) AHMC (appointed 2V June 2021) The following person acted as Company Secretary during the financial year: Mrc Hodgson AHMC Relevant Organlsatlons Audltors- RSM UK A￿111 LLP, St Phillips Point. Temple Row. Bimingham. B2 SAF Bankers - Natwest Bank Plc. 59 The Parade. Leamington Spa. Warwickshire. CV32 4BA Solicitors - Wright Hassall, 0￿mpUS Avenue. Leamington Spa. Wa￿lICkSh1￿, CV34 6BF ashornehill Alm and Objoctlves Purpose of the Charlty The purpose of the College is set out in the objects contained in the charitable company's memorandum of association. In brief this is the ajvancement of educatk)n and leaming and in partlcular the raislng of the staThJards of management and leadership skills across all 8ectors. Alm The aim of the College Is to be a management leadership tralning provider of excellence by developing solutions to fuffil customeTS' trainirtrJ requirements. Expertise is offered in the flelds of leadership. graduate development and rnanagem8nt development through complement of trainers and associates. Charftablo Actlvltles and Publ1¢ Benefft The Trustees have consldered thls matter. in conjunction vith the guldanc8 contained in the Charity Commission's general guidance on puLqic benefit, and have concluded thal.. 1. The aims of the organl8atlon continue to be chariiabl8', 2. The benefits a￿ for the put￿lc, and are not unreasonabty restricted In any way and certainly not by abilty to pay: and 3. The￿ is no detriment or harm arising from the aims or actlvitles. In accordance with aim, the College provkles management tralnlng 8cr088 all business sectots. The training, vthilst focussed at management 18vel, Is availabl8 through dedicated company programmes. Enhancing management skills clearty benefits both the individual an¢J company with an added p)sllive impact on the Btrtish econorny. This provides p8rsonal development and. through y￿rk related assignments arKJ feedback to line managers and HR Directors, organisalional development is embedded post delNery. Delegates benefrt from le8ming within a dlverse communty and AHMC promotes diversty on Irainlng courses to share and learn from a wide range of experiences. The College has developed the Leaming a Development Managers N&tr￿Tk which invofves keynote speakers and covers topical issues across a wide range of the private sector. The benefrts are free￿ availatAe to the memtsrs of these forums. Training is also provided through the Conference Centre facilities: arKI Ihis is a vlab16 58Tvice provision in rts own right. The facilities are booked at prices wh￿h are ￿mPa￿dble wlth other slmilar centres and are available for public and charitsble use. The reserves of the charity are invested in improving the Grade 2. listed premises and Ihe facilities available with the obiedNe of delivering an enhanced training environment to generate future training revenues. The publlc, in the guise of trainirvJ and conference partF¢ipants as well as visttors, continues to enjoy the facilities on offer. As a charity the general publ￿ have the assurance Ihat all the inwme of thè College must be applied for educational purposes. As an eduCat￿nal charity AHMC enjoys tax exemption on educational activities and investment income and gains as these are applied lo the charitable aims. As a tharity the College is also entiued to an 80% reduction on business ashornehill Creating growththroughpeople rates. The financial beneffts rer£lved from these tsx exemptions are all applied for educational purpw)ses. Envlronmental and Safety Responslbllllles In addition to the Charitsble ActNrties. th6 College rnaintains health and safety as a top priority by investing signthcantly in both a safety management system arKI the training and development of staff. A Health & Safety off￿er is in place to ensure a year on year Improvement in ¢ultural behaviour and atkntude to working safely. A commlttee of employees hold regular meetings to discuss H&S issues. Planned audlls of the site. its faciltties 8nd activitles, a￿ undertaken with a report to the Busin885 Management Team, to ensure any necessary action is taken. The College continues to develop its onvironmental policy with money saved through recycling initiatives being reinvested in sustainable energy. Waste management has been improved dr8m8ticalty with much of the waste being recycled; th8 objective being to reduce the carbon footprlnt. Agreements currentfy in place cover the recycling of paper. cardboard. printer cartridges. 918ss, èlectric light bulbs and elethcal harthvare. Old fumiture and educatlonal materials are rewled through the second hand market or donated to other charlties. Managom•nt Th• Board of Trust••* In order to match best practlce guldance on good govemance and lo ensure all Trustees arg actlve and fully involved in the running of the College. the number of Trustees is Ilmited to 12. Thè compositlon of the Board of Trustees is designed to provide a mix of commgrclal and eduCat￿nal expertise to ensure that the charitable objocts of the organisatlon aro aCh￿ved. All Trustees give of their time freely and no remuneration is paid for thelr seNices as a Trustee. The Trustees meet at leasl tw￿8 a year, receiving ￿portS from a Commercial and Strategy Committee and a Flnance and Audit Committee. As the Trustees of the College. the Board is composed of not more than six Trustees nominated and appointed by the Executive Committee of Jaguar Land Rover Llmited. Six additional Trustees are appoint•d by reason of their academic standing or commercial experience. Tru•tee Inductlon and Tralnlng Current Trustees identfy suitable candidales who are invited to serve as Trustees. Potential candidates are apwinted with a vw to their professional competence and experience across a variety of sectors and across the training and conference industries. New Trustees are offered a presentation aboul the hlslory of the College. its aims 8nd objectives. They are also provided with copies of the mernorandum and artlcles of association, latest accounts. recent minules and suttable Charity Commission guidance. On going training is also provided to ensure trustees are Upt￿date ￿th regard to their duties as trustees. This annual training includes. but is not limited to, updates with regard: the College's purpose and benefit to the public.. the COl￿ge'S rules.. whafs best for the College and who it helps, and,. the strategic. financial and operational risks to the College. ashornehill cL*at1ti8￿0wth tlllDu8hF Sub Commlttees The Flnanco and Audit Commlttee meets t¥yice a year. the main dut￿5 of which are.. To approve Ihe annual accounts arKJ trustees report for submission to the Trustees and members. To consider issues raised by the audrtor. To monitor progress against ffinancial targets in the annual plan. Ensure the integrity of financial systoms. The composition of the Flnan&8 and Audlt Committe8 is J Hall. C Barber and J West with C Hodgson in attendance. The Commerclal and Strat•gy Commltt•o also rneels Iwice a year. The maln dutles of the Committee are" To review the progress made in achieving the Tnthes, stratsgy. To consider business development activity. the Colw's operating envlronment and trends in the customer base. Conslder how the obJectNe8 may b8 aCh￿l￿d In future years. The compoS￿10n of the Commérclal and Strategy Cornmitteè is J West. A Chick, C Barber. M Jennlngs and S IsheTh•￿K>d. Key Management Personnel and Bu8ln•s8 IAanag•m•nl T•am The Trustees deleg8te daY-t￿daY control of the College to the Managlng Dlr8Ctor, J W8St, who is noled, alongside the Trustees. as the Key Management Personnel. Trustees rerRive no remuneratlon in respect of their duties as Trustees. The Managing Director is 8 seconded ernploy68 of Jaguar Land Rover. Salary. pension and nats'onal insurance wntrfbutions for the Managing Director are govemed a￿1 settled by Jaguar Land Rover. The Managing Dlrector is fonnally athiged by the Business Man8gement Team {BMT}. Th8 team consists of professional managers of the trdlning. conference, support and finance fvnclions and meels fomially each month to review perfonnancé, future plans, prospects and re80urce8. Multi-disciplinary teams, usually led by BMT members, are appointed to progress speclflc objectivés approved by the Trustees. Related Partles and Dependency The College is govemed by Trustees (vtho 8180 act as MembeTS of the College) appointed by Jaguar Land Rover Llmited vthich Is part of the Tata Group of companies. The College has no material dependency upon free services or other intangible in￿rne. A trading subsidiary. Ashorne Hill (Trading) Limiied. has been establlshed to transact non- charitable business and gift proffts b&k to the College. ashornehill Stratoglc Roport Rlsk Management A Risk Register of the major risks to whth the College is exposed ts in pface and is fomally reviewed and amended annually. Systems and procedures are in place to mitigate risks and the progress against actlons revwed quartety. The principal risks to the Colle98 have been Klentffied as.. Governan￿. with respect to trustee conflicts of interest,. Operdtlonal, in tems of coMpetit￿n and fire, and.. Financial, being the risk of over-dependence on single income sources. These risks are managed through Trustees fvlly declaring wnflids of interest on an annual basis, management analysis and benchmathng of competttors, annual reviews of fire protection sy8tem8, controls and processes, and a strategic plan to dlversrfy the College customer base. In addition, the impact on the College due to regulatory changes is constantly reviewed Ix)th internally and by extemal specialists. Intemal control risks ar8 also mlnlmls8d by th8 implementation of procedures for authorisation of all trans8clions and projects and the policies of the Qualty Manag8m8nt System. pr￿edureS are in place lo ensure compliance with regulations. These procedures and kK)li¢ie$ are periodically reviewed to ensure that they continue to meet requirements. R￿Pons• to Nmd Most of the training provision is developed at the specific request of the client to meet either change management or ￿￿engineering in11￿live. The training provKled covers all levels of manag8m8nt from 18am leaders and new graduates lo middle and senior management. Close Ilaison wrth ¢llents along w6th a well-m8naged feedback system Is In place and Is used to gauge s8tisfaction of the deliv8rylcontent of training and the leaming environment. All feedback Is channelled into regular reviews and 8Ctioned through the knowledge management and the facllities datsbases. All accepted changes then form the basis for future training programme5, service provisK*n and facilrty enhantxments. Fundlng of Aetlvltl•8 Activltles are funded by the charges made lo clients for the provision of training, venu8 facilities and associated seNices. Additional income is earned from interest on bank deposits, r8nts from properties not currently used for training purp)ses arKI from re¢harges for telephone and other seThtces provided for delegates. During the period ending 31 March 2021, income was generated from the followin9 sources.. 2020-21 £000 675 2019-20 £000 4.110 202 26 59 Fees eamed Trading Subsidiary (Gift Aid) Grant Rents and Sundry Income Investment Income Other Income 930 5% <1% <1° 53% 32 <1% <1% <1° n of the charitab￿ wnpany and enable ashornehill CTratin8wwththro￿peOp]e them to ensure that the financial statements ￿mplY with the Companies Act 2006 and also responsible for ensuriro that the assets are properly applied in accordance wth Charity Law. They are also responsible for safeguarding the assets of the charilable company and the group and hence for taking reasonable Steps for the prevention and detection of fraud and other irregularities. 10. Statement on Dls¢losur• of Infomiatlon to th• Audttorn So far as each TnJste8 ￿ aware. there Is no relevant audtl infonnation of which the Charity's auditors are unaware. Each Trustee has taken all the steps (such as maklng enquirl8s of other Trustees and the auditors and any other steps required by the Trustee's duty to exercise due care, skill and dlligen¢el that he oughl to have taken in his duty as a Truste6 in order to make himself aware of any relevant audii infomation and to establish that the Charty'5 auditors are aware of that infomiation. 11. Audltor A resolution to reappoint RSM UK Audit LLP as audlior for th8 ensulng year will be proposed at the forthcoming annual generdl rneeling. Approved by the Board of Tru8t688 and sKJned on its béhalf by: . Trust88 Date I 2021 Trustee Dat8 l y 1012021 ashornehill INDEPENDEHf AUDifoR'S REPORT TO THE MEIIIBERS OF ASHORNE HILL MANAGEMENT COLLEGE Oplnlon We have audited the finan&al slaternents ol Ashomè Hill Mwemenl (th• 'par8nt th￿1t9b￿ company'l and its subsidiaries (the 'groL¢)'I for thè ￿#r eTrJed 31 March 2￿21 wh￿h ￿MPrIse the Consolidated Statemanl of Financial AdVIt￿, th6 Consolidated Bal￿ Sheels. the Con5(Aidated Cash Fbw Stslement and notas to the flnancAal 5talem8nts, indudiro s¥Jnfficant actomliThJ px)Iiw. The finanual reportsng fram6%￿rk that has b8en applied in their weparalion is ap￿1¢able ￿ and United ￿'￿￿0M Accounb"ng Stand#rd5. IndE￿ir£ FRS 102 'Th• Financid Rewrtir¥J Stsndaftl appl￿ in ts UK RoFAth of Ir•larKI" (UNte(l Gen•rnlty Ace•pt•d Accounting Practica). In ourothlon Ih6ffinand81 stat•manls". l¥• a tru8 and tsir vw4 01 the slats ofts gro￿.8 #rby thts par•nt chwiith cc4nwy'• •ff8lr& as at 31 M8rth 2021 and of the gr¢yJp's incornirKJ rnsour¢•6 •KI aFWKation ol r•wrw, ts4udkng Its Income end eX￿￿+ture, lor the year end￿1,. havè b8en pr¢wly preparwj in lfjTrJd￿ Genor81ty Acthpt*l A¢￿n￿rIa Practice,. and have been prepared In the wulrements of lh• Comwl¢s ALI 2C#)6 and the ChaAO•s Ac12011. 8a•l• for oplnlon We havo beon appolnl¢d audrtorn urth the COMP￿￿¥ Ad 2C*)6 8nd sgthl 151 of Ihfr Charfties Act 2011 and rewrt In 0¢¢orda￿ with those Acts. W6 conduct&# our auilil in a¢cordance wih Intamal￿n8I Standards on Audrtirg IUKI IISAS IUKII and ¥pplic8ble law. Our ra$p￿St¥ll&S wthler1￿ stsrwJwd8 •rn fLKthw dwiib•d in th• Auditorf8 106pons￿lI￿•S for th• aud of the finanoal sl8tem8nts SOCI￿ ol our rewjrt. We are in¢Yependent of Ihè group oThJ parent charitable conpany In ￿¢of￿anCe the èthical r￿uireMents Ih8¢ a￿ rnlevont to our ￿d[t of the finandal st8tomenls in thè VK. Including th• FRC $ Elli￿￿ Slandard and wa h85* fuMlll•d our olh•r eb*al fespms1b51it￿S in &c¢ord•nco vAth thw rgquirements. We that th• audit h￿0 oirt&in•J Is suffiLa*rt a￿) appropriate to P￿￿d0 b&sis for our opinK)n. Conclu•l¢)n• r•latlng to golro cone•m In audillng the finan￿al staternents, wa have Co￿￿d￿j that th• I1￿￿•1, u8• oflh• gr4ry c4>rKwi of pKcounllng In th8 of Ihe finwK4al Sts1￿￿ts is 8pprDwlale. Based on have parfonnsd, ￿ have Th)1 Idents￿ matèrial unr*rt8intie6 relating to evènts or coThJitths that, ind￿￿lu?1￿ orcolwvety. may cast signfficant Owb¢ on ts gr￿jp'S orp8Tenl ¢harft•bl& eKJmpany'$ #bil'ty lo ¢ontinue as a golrrj cOn￿n for a PWK4J Of￿ kni ts¥dve rnonths lffjm when tha finand 518tem8nts are authoFiswJ for issue. Our wponsiblit￿$ and the ￿SponSI￿1rtlos of th& Intstw res￿ lo go*ffj Conc￿ are described in the rdevant sections of this rep)rt. Oth•r InforM￿on Th8 other information o*nprtses thè infomwtw indwJ&J in the TnAst•as Annud RgFQrt otherthan Ihe finandAI ststements and our audltols rwrt th¢r•on. The trvstees we resp￿￿1b18 for Ihe other infomiation contained wlthin tha TNst8es Annual ReFQrt Our c¢)ir¥on on Ihe finarLyal statem￿ts does not COV8f thè other inlormatK¢n and, except to the ext8nt oth￿￿4 •xFIK>lly 3tsted in our reFxrt not exrKess any lo￿ ofassurnnc4 conduslon thereon. Our r&s￿n91￿.11ty is to read the other inforn￿￿ aTrJ, in (kyng g). Vknetr￿rthe Olher infomiation15 Mat￿allY intt)n5iStent with the financial Stat￿nts or our k[￿ oblained in the o)utse oftha 8udit or otheMse appears to be materialty mi8Stated. 11 we identify su¢* maleri4 IrKor￿lSlenC¥0g or apparent rn8terial mis5talements. we are requi￿ to detemiinè vhther thi8 gNes rise to a material rnissiatement in the finanaal ststernents themsdves. 11, bas￿ on Ihe M)rk we have perfOrn￿d, ￿ Cond￿18 that th￿e is a rnat￿al misstat8m8nt of this other infomiath)n. we are requI￿j io reFQrt thal f*. ashornehill crtstlngwrththr0￿1Feop]e We have rK)thn9 to reF#Yt in rwJ8rd. Oplnlons on oth•r prescrlbed by th• ConyAnlos Act 2006 In our opinK)n, b858d on the ￿￿rk undertaken in Ihg ¢xKJrse of the wdil.. the inforn8lion given in Ihe Trustees, Report lor the fin¥thl yoar for vthlc* the finaThial staterngnts arg prepared Ss t￿￿￿tent tha stat8m8nts,' and the Trustees. Réport ha$ been prepared in xc¥Jrdar#x wilh applKable legal wUNem￿ts. Matt•r• on whlch w• ar• rnqulr•d to r•wt by •xe•pllon In th6 ligm of tho kncv•1￿9ts and u1￿6￿ta￿lIfvj of Ihe gThp and lh8 pafwbt charrtabkg c4)rnpany and their environment obtsined ￿ th8 ry)urse of ￿ audiL we hwe ￿t KJ8nbW m*ri81 mb6tatwn8nts In the Tfu8t8•8' Report. Wé hav• nothiNJ to rèwjrt in r•sFrft d the fOlkA¥1￿ ￿tter3 c￿￿p￿leS Act 2006 and tho CharfU88 Ad 2011 r￿ulTS W to re￿rt io you rf. in our O￿n￿)n.. qvale and suffvent ac[￿un￿n9 I￿OrdS hbve rKJl k•pt by Ihe paront eharitabl• or retums adequate forouraudh hav8 ￿t b88n fwv•J from l>rnnrhg5 rvJl Visit￿ by u8,. or lh¢ parèni chaiitabb company financial statwnenls are in aGre￿ent with the aculun￿r@ records and retums.. Of hav• not raC•N￿ all thè infomab'on and explanolws we require lor our audtt.. or the Trustees nol ￿tIlled to prepare th• financlal stst8rnents In ￿co￿ance vlth th• small companies r8glrne and take 8dvantage ol the smdl ¢J)mpaniès èxèmplion from fv rg4uIrem￿t to 8 Str8t•gK RW Of in pr8pantYJ ￿ T￿1•￿. RWL R••pon•lblllll•• of tru•lw• As explalned more fulty ￿ the Slat•m•nt 0fTr￿S*' n8p￿￿11￿ sst c4rt ffi p4g& 7. trustees (who are 8180 dirtctots ol thè tharita￿ g)mpany for Ihe purs￿e8 ol ccynpary lawl a￿ responsiblelor the preparath'on of Ihe flnandal stolem￿ts and lor saithd Ih81 they gfve 8 true and f8ir and for suth intema conlrd a9 the trustoes det•rmlne Is nec•ss8ry to onablè th• pr•poraUM of financ*g1 st¥tw•ts that art from mat8nal mlSst8l•m￿l. wh•th8r ¢Ju• to fr8ua or arror. In prepadro the flnwKaal Ststwnwts. the InAtseB a￿ Tesporthknb for as8as%ThJ the group's ￿ par•nt thBntsblè cornyny's ability to conts"ThJ• 95 a g￿n9 concam, disdosing, a5 ¥>plub18, rnatte￿ relaled lo 90ing cx)rrAm and usiry lh8 going Lx)r￿rn basi5 of acrountiThJ unless the Iwsleg5 eilher intend lo IkJuld8te the group or parent thwrt8bK8 cornpany or to C8￿ opwation6. or have rK¢ wltstic *tematNe but lo do so. Audltof• mportlblllth• lorth• *udlt oltho Ilnanclal ¥tatem•nts Our obJgCtlve5 are to obtain reawnable assurance *K)Ut vknether the fin￿¢181 Slaternenls as a w￿)18 ar• frn8 Irom rnaterial rnis5taternent. whether due lo fra￿j or error, is$￿ an aJJJrtorfs r•port that int*Jdes our opinion. Roasonable assurwth is a high level ol a5suranLY, bui is a gu8ranl8e th8t an audit condwted in a¢ry)rden￿ wilh ISAS IUKI will 8Ws delerA a mat￿81 M￿Statement when il exisls. Misststernenls can arisè from fraud or error and are ccMisbJwed material rf. wthAJualty or in the tygrwJatè, Ilw LX)uld reawn8bly bg exP￿ted to lrfuencfr th• ec0￿M￿ d￿3$Tor6 of usets tthen on the basi¥ ol these finarKial statemerts. The •xt•nt to whlch th• audll Tm conxld•r•d ¢apalJl• of d•t•ctlDq Irr•gularlll•s, Includln9 fraud Irregularities are inslarKw of non-O)mplianc* law5 and regulabDns. The Obl￿t￿85 of our audit are to obtsin sUffic￿nt appropriate ajdit eVKIen￿ warth'ng Comp1k￿Ce with regU￿tiOnS th81 have a direct eff￿t on th8 det8rrnin8tion of material ar￿Unts and discknures in Ihe stslements. to perfomi audrt prOc￿ureS to help Id￿lty instance5 of ￿n-￿Imp1K8n￿ oiher laws aThJ rWJuIat￿ns Ihat may have a material Off￿t on Iho fina￿la1 stat&nents, and to res￿nd appropriaidy to ￿enI[fi￿ gr $u5mgd non-(r)mgliance wilh laws and rwJul*ions id•ntir￿d tlurirrfJ ￿ •Jdit. In relats.on to fraud. the ot*Nes of ow audtt are and assess thè risk of materi81 rnis5t8t8ment of th8 finan￿81 5tatem8r)ts duè to fraud. to obtain S￿ropriate audit eviden￿ w8rding the assessed risks ol rn8terial rnisstalwn￿t due to fr8ud through des#JnirMJ ￿ impthentiThJ appropriate reSp￿Se$ and to reswn(S propriatdy to fraud or susp&#ed fraud id￿t[fied durirrfJ the a￿￿rt. -10 ashornehill However, it Is the wimary ￿￿)nsibilty d manag￿n￿t. ￿1h the ovwsyhl of those Charged with ￿¥8manCe, to ensure that the 8ntity'S operatitins are (x)ndLthS in the FThts¥)ns of I￿ and regulth.ons and for the prevent*)n and detectK)n of fraud. In irJ8ntrfying and assessirKJ risks of material rnlsstatem￿t in ￿SpeCt of irrvwLw￿eS. induding fraud. the group audit eng&Jement t8wn'. obtsined an underslanding of the natu￿ of Ihe S￿r, indudiry the legaf and regulatory frame￿rk that the group and parent charitatAe cthnpany opwate ￿ and the grovp pawt tharitsble company arg ¢Y)m￿ying wAlh the kgal and regulatory frarYwAth., inquired of man&JemenL and those charged with WVeM￿ce, *x>ut Ihwr ly￿ identrfi¢atk)n assossm&rt of the risks of irregulanlies. indudin9 any known or alleged instsnces of fraud., dis(yJssed matt8r5 8t